Statutory membership criteria cannot be expanded by internal resolutions, and eligible applicants acquire an enforceable right to admission.

A notified membership scheme must be applied according to its stated eligibility conditions, and an administrative body cannot add extra qualifications through later resolutions or internal guidelines. The Court found that the applicant met the requirements in the 15 May 1975 notification, namely service as secretary on the specified date and the prescribed academic qualifications, so rejection for lack of further practical experience was unsustainable. Once those conditions were satisfied, the Institute had a legal duty to admit him, and that right was enforceable in writ jurisdiction. The subsequent dissolution of the company did not defeat the pending writ proceedings or the relief sought against the successor Institute.

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Issues: (i) Whether the petitioner satisfied the qualifications prescribed in the notification dated 15 May 1975 for enrolment as an associate member of the Institute; (ii) Whether the Institute had a corresponding legal duty to admit the petitioner and the rejection order was enforceable in writ jurisdiction.

Issue (i): Whether the petitioner satisfied the qualifications prescribed in the notification dated 15 May 1975 for enrolment as an associate member of the Institute.

Analysis: The notification, read with the scheme of section 383A and section 2(45) of the Companies Act, 1956, prescribed only two material requirements for the relevant category of working secretaries: the applicant had to be serving as secretary on the specified date and had to possess the stated academic qualifications. No additional requirement of further practical experience could be introduced by executive guidelines or internal procedures. The Council's later resolutions could not alter the terms of the notification, and the petitioner fell within the category expressly covered by it.

Conclusion: The petitioner satisfied the prescribed qualifications and the rejection on the ground of insufficient practical experience was unsustainable.

Issue (ii): Whether the Institute had a corresponding legal duty to admit the petitioner and the rejection order was enforceable in writ jurisdiction.

Analysis: Once the petitioner met the prescribed conditions, the Institute was under a legal obligation to admit him, and the right to membership was judicially enforceable. The Court also noted that the subsequent dissolution of the company under sections 31 and 32(4) of the Company Secretaries Act, 1980 did not defeat the pending writ proceedings or the relief claimed against the successor Institute.

Conclusion: The Institute was bound to admit the petitioner, and the writ petition was maintainable and capable of effective enforcement.

Final Conclusion: The refusal to enrol the petitioner was quashed and the respondents were directed to admit him as an associate member, with costs left to be borne by the parties themselves.

Ratio Decidendi: Where a statutory or notified membership scheme prescribes specific eligibility conditions, an administrative body cannot add extra qualifications by internal resolution, and once the prescribed conditions are met, admission becomes a legally enforceable duty.

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